23037_Elan Indian Trail_Request for Additional Assessment Letter_08.22.2019

August 22, 2019
Ben Liebetrau, Vice President
Greystar GP II, LLC
465 Meeting Street, Suite 500
Charleston, SC 29403
[e-mail]

Subject: Additional Assessment Request
Elan Indian Trail
Southeast of the Intersection of Chestnut Parkway and W US Highway 74
Parcels 07105004 and 07105005D
Indian Trail, Union County
Brownfields Project Number 23037-19-090

Dear Mr. Liebetrau,
The North Carolina Department of Environmental Quality (DEQ), Brownfields Program has reviewed the
documents submitted with the Brownfields Property Application for the Elan Indian Trail property located
southeast of the intersection of Chestnut Parkway and W US Highway 74, Union County. The following
is a summary of the reports reviewed:

Based on our review of these documents and information garnered from adjacent properties, data gaps
were identified. Additional assessment activities, as outlined below, are required to assist in making risk
management decisions for inclusion in the Brownfields Agreement (BFA). Prior to conducting field
activities, a work plan should be submitted to DEQ for review and approval. The work plan should
include a description of the sampling and analytical methods to be utilized and a map depicting the proposed
sample locations. The most recent Inactive Hazardous Sites Program Guidelines for Assessment and
Cleanup (http://portal.ncdenr.org/web/wm/sf/ihs/ihsguide) and the November 2018 DEQ Brownfields
Assessment Work Plan Checklist (attached) should be followed. Request Level 2 QA/QC data packages
from a N.C. certified environmental laboratory. Collect one duplicate sample for all analysis per every 5%
of samples. All sample locations are referenced in the attached map.

Report Title Author Date
Phase I Environmental Site Assessment Resolve Environmental
Services, PLLC
May 15, 2019
Phase II Environmental Site Assessment
Recommendation Letter
Resolve Environmental
Services, PLLC
May 23, 2019

Elan Indian Trail
August 22, 2019
Page 2

1) Groundwater Sampling: Install a total of four monitoring wells at the following locations:

a. Three monitoring wells along the southeastern property boundary immediately
downgradient of the former Catawba Food Mart #4 LUST site (currently Walgreens) as
shown in the attached figure. The monitoring well located in the middle of the row of
three wells should be completed within the underlying bedrock to a depth of approximately
45 feet below ground surface (ft BGS) as referenced in the Comprehensive Site Assessment
Report completed by Shield Engineering, Inc. for the Catawba Food Mart #4 dated
February, 2004. The two outside monitoring wells should be completed within the
surficial aquifer with the screened portion of the well straddling the water table.
b. One monitoring well should be completed near the north central portion of the northern
parcel (07105005D) as referenced in the attached figure. This monitoring well should be
completed within the surficial aquifer with the screened portion of the well straddling the
water table.

Monitoring wells should be constructed and developed in accordance with the standards presented
in the North Carolina Administrative Code (NCAC) Title 15A Subchapter 2C and the US EPA
Region 4 Science and Ecosystem Support Division Guidance. Monitoring wells should be
surveyed to determine accurate groundwater flow across the Brownfields Property. Following well
development, monitoring wells should be sampled for Volatile Organic Compounds (VOCs) by
EPA Method 8260, Semi-VOCs (SVOCs) by EPA Method 8270, and Resource Conservation and
Recovery Act (RCRA) Metals by EPA Method 6020.

2) Soil Sampling:

a. Collect one surficial soil sample from the 0-2 ft BGS depth interval from each of the locations
referenced as circles in the attached figure. If impacted soils are observed at 2 ft BGS based
on visual, olfactory, and/or photoionization detector (PID) readings, collect additional samples
as warranted up to a maximum total depth of 5 ft BGS. Soil samples across the property
represented by a yellow circle in the attached figure should be analyzed for VOCs by EPA
Method 8260, SVOCs by EPA Method 8270, and RCRA Metals by EPA Method 6020. Soil
samples located along the transmission line corridor represented by a red circle in the attached
figure should be analyzed for Organophosphorus Pesticides (OPPs) by EPA Method 8141B,
Organochlorine Pesticides (OCPs) by EPA Method 8081B, and RCRA Metals by EPA Method
6020. Collect and have the laboratory hold an additional sample aliquot for possible analysis
of Hexavalent Chromium via EPA Method 7199 depending on results of RCRA Metals
analysis

3) Surface Water/Sediment Sampling: Collect collocated surface water and sediment samples at
locations representing the influent and effluent of the stream running north to south across the
Brownfields Property. Samples should be collected in accordance with the Operating Procedures
established by the US EPA Region 4 Science and Ecosystem Support Division (SESD) for Surface
Water Sampling (December 16, 2016) and Sediment Sampling (August 21, 2014). Samples should
be analyzed for Volatile Organic Compounds (VOCs) by EPA Method 8260, Semi-VOCs
(SVOCs) by EPA Method 8270, and Resource Conservation and Recovery Act (RCRA) Metals
by EPA Method 6020.

Elan Indian Trail
August 22, 2019
Page 3

4) Receptor Survey: Complete the enclosed Brownfields Property receptor survey and include as an
attachment to the additional Assessment Report.

Report and Figures: Upon receipt of analytical data, submit a summary report with a description of field
activities, tabulated data in comparison to applicable screening levels, and the laboratory data packet with
applicable QA/QC documentation, provide a site plan with well locations, locations of sample points, and
current site structures. Provide a potentiometric map for groundwater flow and concentration maps for
contaminants detected above applicable standards. Please note, all sample points may need to be included
on the future Brownfields plat. DEQ recommends having sample locations surveyed at the time of
collection for use in preparation of the Brownfields plat.

Please provide the Work Plan for additional assessment activities as soon as you are able. If you have
questions about this correspondence or require additional information, please feel free to contact me by
phone at [phone] or by email at [e-mail].

Sincerely,
Cody J. Cannon
Brownfields Project Manager

ec: Josh Glover, Greystar Real Estate Partners
Zach Spencer, Greystar Real Estate Partners
Mary Katherine Stukes, Parker Poe Adams & Bernstein
Terry D. Kennedy, P.G., Resolve Environmental Services, PLLC